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DPA case 1809/452/18 – Complaint Upheld (Finland, 2020)

Complaint Upheld
DPA Tietosuojavaltuutetu29 July 2020Finland
final
Complaint Upheld

Privacy enforcement record

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A Finnish data protection authority upheld a complaint about a housing cooperative's electric lock system. The cooperative did not inform residents about how their access data was being handled, which is important for protecting personal privacy.

What happened

The authority found that the housing cooperative unlawfully processed personal data related to the electric lock system.

Who was affected

Residents of the apartment building who used the electric lock system.

What the authority found

The authority ruled that the housing cooperative did not have a legal basis for processing the personal data from the electric lock system.

Why this matters

This case emphasizes the need for transparency in how personal data is managed. Housing cooperatives should ensure they inform residents about data processing activities.

Recorded legal citations
Automatically processed
Art. 58(2)(d) GDPR
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Art. 58(2)(d) GDPR

Original imported citations before automated processing; the processing history does not establish independent verification.

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Full Legal Summary
Detailed

An applicant contacted the Finnish DPA, expressing data protection concerns over the housing cooperative's electric lock system and its implementation. According to the applicant, the residents were not informed about the details of the lock system. The electric lock system in question is installed at the entrance doors of the apartment building. According to the housing cooperative (controller), they do not receive any information from the lock, and the lock company that manages the system only allows access to the data at the request of the police. The housing cooperative therefore had made an assessment that the use of the electric lock system did not involve processing of personal data. The door opening data is personal data. Data does not need to be directly linked to the data subject in order to qualify as personal data. Individuals that use the electric keys can be identified in instances where the key identification information is matched with a specific apartment. Especially those residents that are living alone, they can in practice be identified with a high degree of certainty. The processing of personal data always requires a legal basis for processing, and compliance with the other data protection provisions. As the controller had assessed that no personal data was being processed, it had not defined the legal basis for processing the data, nor in any other way ensured the timely fulfillment of the obligations to the controller under the GDRP. The processing of the personal data has therefore been unlawful. As per Article 58(2) d, the Finnish DPA ordered the housing cooperative to bring the personal data processing activities in line with GDPR. The decision is not final.

Outcome

Complaint Upheld

A data subject complaint that was upheld by the DPA.

Related Enforcement Actions (0)

No other enforcement actions found for DPA case 1809/452/18 in FI

This is the only recorded action for this entity in this jurisdiction.

Details

Decision Date

29 July 2020

Authority

DPA Tietosuojavaltuutetu

GDPRhub ID

gdprhub-2673

About this data

Data: GDPRhub (noyb.eu)
Licensed under CC BY-NC-SA 4.0
Automatically normalized and classified

Cite as: Cookie Fines. DPA case 1809/452/18 - Finland (2020). Retrieved from cookiefines.eu

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